Ravindra Matadin Modi vs. Income Tax Officer

Parties Involved

Facts Summary

The appeal was filed by the assessee against the order of the Ld. NFAC dated 06-Jan-2026 for the Assessment Year 2019-20. The assessee raised several grounds of appeal, including the nullity of the assessment order, jurisdictional issues, time-barred notice, improper approval by the PCIT, and disallowance of deductions. The assessee also challenged the levy of interest without proper direction in the assessment order. The assessee requested that the grounds of appeal be admitted as they were purely legal issues.…

Legal Issues

• 1. The nullity of the assessment order due to lack of pecuniary jurisdiction of the ITO.
• 2. The time-barred notice issued under section 148 of the Act.
• 3. The validity of the approval granted by the PCIT under section 151 of the Act.
• 4. The validity of the assumption of jurisdiction under section 148 of the Act.
• 5. The disallowance of deduction claimed under section 80GGC of Rs. 2,00,000/-.
• 6. The levy of interest under sections 234B and 234C of the Act through the computation sheet without any direction in the assessment order.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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